Privacy Policy

    Last update: November 10, 2025

    1. Introduction

    This privacy policy describes Amical's practices regarding the collection, use, retention, and sharing of your personal information when you use our AI phone service designed to provide social and cognitive support to seniors.

    Amical is operated by 9526-1061 Québec inc., a company registered in Quebec, Canada. Our head office is located at 2-125 Boulevard Charest E Québec QC G1K 3G5 Canada. You can contact us for any questions related to this privacy policy by email at [email protected].

    2. Data Collection

    At Amical, we collect and use data to improve user experience, ensure the quality of our services, and safeguard our legal protection. Please note that data is collected and processed differently depending on its purpose: data collected for legal protection purposes is not anonymized, while data collected for product and AI improvement is anonymized.

    2.1 Types of data collected

    • Personal data:
      • First and last name.
      • Date of birth.
      • Contact details (address, email, phone number).
      • Information collected during the initial onboarding, which may include:
        • Data provided by the residence (for example, via the "Life Book").
        • Data submitted via our online form.
        • Any other information voluntarily shared by family members or caregivers, including medical information deemed necessary.
    • Health data:
      • Type and level of cognitive impairment (e.g., Alzheimer's, vascular aphasia, dementia level, Lewy body).
    • Usage data:
      • Complete recordings and transcripts of conversations with the AI.
      • Phone usage statistics (call frequency, duration of interactions).
    • Technical data:
      • IP address and connection data.
      • Performance information for diagnosing and troubleshooting technical issues.

    2.2 Methods of collection

    • Direct interactions: Data is collected when using the AI phone, such as conversations or incoming calls.
    • Initial onboarding: Information is collected at the time of setting up the service, including data provided by the residence or via our online form.
    • Scheduled calls: Conversations initiated by the AI to interact with the user.

    2.3 Consent

    We collect data only after obtaining clear and informed consent. If the user is not able to consent, consent will be obtained from the legal guardian. You have the option to withdraw your consent at any time by contacting us.

    3. Use of Data

    The data collected by Amical is used exclusively to provide, improve, and personalize our services. We are committed to limiting the use of data to the purposes described below:

    3.1 Main purposes

    The data collected by Amical is used for the following purposes:

    1. Improvement of user experience
      • Description: Personalization of conversations with the AI based on preferences and provided information (interests, tone of interactions, etc.). Adapting the AI's responses for optimal support.
      • Legal basis: Consent, Legitimate interest
      • Data categories: Personal data, Usage data
    2. Technical support and maintenance
      • Description: Analyzing technical performance, diagnosing and resolving issues. Continuous update and improvement of features.
      • Legal basis: Contractual necessity
      • Data categories: Technical data
    3. Proactive communication
      • Description: Scheduled calls by the AI. Sending notifications to relatives or caregivers (e.g., in case of detecting signs of emotional distress).
      • Legal basis: Consent
      • Data categories: Personal data, Usage data
    4. Analysis and monitoring
      • Description: Producing reports for caregivers or relatives. Detecting signs of emotional distress or suicidal thoughts.
      • Legal basis: Consent, Legitimate interest
      • Data categories: Usage data
    5. Research and analyses
      • Description: Anonymized studies to understand the impact of Amical, improve the AI, and develop new services. Possible sharing with research partners (e.g., CRIUGM, CIUSSS). Data used for such purposes requires the explicit additional written consent of the residence and of the residents. General user data is not used for research unless there is a specific research agreement in place with the care facility and the residents or their representatives.
      • Legal basis: Explicit additional written consent (residence and residents); legitimate interest only where a specific research agreement applies
      • Data categories: Usage data (anonymized), Voice recordings (anonymized)
    6. Legal protection
      • Description: Retention of complete recordings and transcripts, as well as voice data, with identifiers for control, prosecution, or defense purposes in case of litigation.
      • Legal basis: Legal obligation
      • Data categories: Recordings and transcripts of conversations, Voice data

    Sharing data with third parties:

    We may share certain data with trusted third parties who help us provide and improve the Amical service. These third parties include:

    We take steps to ensure that these third parties adhere to high standards of data security and privacy. We only share the data necessary for the performance of their services and require that they use it only for the specified purposes.

    3.2 Usage limits

    • No targeted advertising: Data is never used for advertising or external marketing purposes.
    • No data re-selling: We do not re-sell your data to other companies for the purpose of selling a product or service to end users.

    3.3 Security and compliance

    All data is used in accordance with Law 25 in Quebec, PIPEDA in Canada, the GDPR in Europe, and other applicable data privacy regulations.

    4. Data security

    The security of your data is a top priority for Amical. We are committed to strictly adhering to the requirements of Law 25 on the protection of personal information and implementing strict technical and organizational measures to protect your information from unauthorized access, misuse, disclosure, alteration, or destruction.

    Our security measures include:

    • Compliance with Law 25: Amical is committed to strictly adhering to the requirements of Law 25 on the protection of personal information. All data collected will be processed in accordance with this law and the highest standards of privacy.
    • Data encryption (Encryption at Rest): Sensitive user data, such as conversation transcripts, personal information, and health data, will be encrypted when stored on our servers, thus ensuring protection against unauthorized access.
    • Controlled access to data: Access to the data will be strictly limited to authorized personnel, and each access will be logged to ensure traceability. Two-factor authentication (2FA) will be implemented to reinforce account security.
    • Infrastructure isolation (VPC): Amical's infrastructure will be isolated within a virtual private cloud (VPC) to minimize the risks of cyber attacks and unauthorized access.
    • Monitoring and alerts: A continuous monitoring system will be in place to detect any suspicious activity. Alerts will be generated in real-time in case of anomalies or intrusion attempts.
    • Vulnerability management: Regular vulnerability scans will be conducted to identify and fix potential security flaws. We use cutting-edge tools and techniques to ensure the security of our system.
    • Security updates: Security updates will be applied regularly to protect the system against the latest threats and vulnerabilities.
    • Transmission security: We use the HTTPS protocol to encrypt data during transmission between your device and our servers, thus ensuring the confidentiality and integrity of your information.
    • Voice data security: We pay particular attention to the security of voice data. Voice recordings are processed and stored with the strictest security measures, and access to this data is limited to authorized personnel. Voice recordings used for product improvement are anonymized and all sensitive data is deleted before use.

    Data management for different purposes:

    • Legal protection: Data collected for legal protection purposes, such as recordings and transcripts of conversations, as well as voice data, are retained with identifiers. Access to this data is restricted and controlled, reserved for key employees and used only for control, prosecution, or defense purposes in case of litigation.
    • Product and AI improvement: Data used to train our AI, such as anonymized recordings and transcripts, do not contain any information that could identify users. Access to this data is restricted to the technical team and used only to improve the performance and accuracy of the AI.

    5. Data retention

    We retain your data for as long as necessary to achieve the purposes described in this privacy policy, and for a maximum of 7 years, unless a longer duration is stated in writing in a separate agreement.

    • Shorter retention policy: Users may set a shorter data retention policy. However, we may not be able to provide specific features, such as alerts, if the data retention period is too short or if no data is kept.
    • Call durations and call costs: Call durations and call costs are kept indefinitely by Amical to monitor product usage and business performance.

    6. User rights

    You have certain rights concerning your personal data, including:

    • Right of access: You can request access to the personal data we hold about you by contacting us by email at [email protected]. We will respond within 30 business days.
    • Right of rectification: You can request the correction of any inaccurate or incomplete information by contacting us by email at [email protected].
    • Right of deletion: You can request the deletion of your personal data, subject to certain legal exceptions, by contacting us by email at [email protected].
    • Right of opposition: You can oppose the processing of your personal data in certain circumstances by contacting us by email at [email protected].
    • Right to portability: You can request to receive your personal data in a portable format by contacting us by email at [email protected].

    7. International data transfers

    Your information may be transferred and processed in the United States. Data protection laws in the United States may differ from those in your country of residence. By using our services, you consent to this transfer.

    8. Minors

    Our services are not intended for individuals under the age of 18.

    9. Policy updates

    We may update this privacy policy from time to time to reflect changes in our practices or legislation. We will inform you of any significant changes by posting the new version on our website or by other appropriate means.

    10. Contact

    If you have any questions or concerns regarding this privacy policy, please contact us at:

    Amical

    Email: [email protected]

    Data Controller:

    9526-1061 Québec inc.

    Microsoft information:

    Address : 2-125 Charest E, G1K3G5, Québec, QC, Canada

    Microsoft user ID; 197657350

    Microsoft entra tenant ; amicalai.microsoft.com

    Microsoft publisher ID; amical-ai

    Microsoft contact ; FX Ratté, [email protected]

    Organization domain ; amical-ai.com